A bipartisan group in Congress is tackling the topic of USF reform. They created a portal to solicit comments, which are not being made available to the public. I provided comments to the group on two topics.
The first is Lifeline support, specifically for low-income MDUs. There are two issues faced by those trying to bring broadband to MDUs that have tenants who can’t afford a broadband subscription. The first issue is bringing the needed infrastructure for better broadband. There was hope that BEAD might provide some of the needed solution since non-deployment funds could be used to upgrade low-income MDUs. However, it looks like NTIA might not give the non-deployment funds to states, even though that was mandated by Congress. I’m working with some non-profits that are looking for other ways to fund infrastructure upgrades.
The bigger issue is that the landlords or ISPs that serve low-income MDUs need some ongoing subsidy since tenants can’t afford to cover the cost of broadband. Lifeline can be used for that purpose today in a limited way. However, most Lifeline recipients direct the savings to their cellphone rather than to home broadband.
I’ve suggested some changes to Lifeline that could make it a powerful tool for improving broadband in low-income MDUs.
- At least for these MDUs, the FCC should double the current $9.25 Lifeline subsidy. That would be enough to make a meaningful subsidy for monthly broadband for a building. It would be great if the Lifeline subsidy were increased in the future for inflation. The $9.25 subsidy meant a lot more when it was created in 1997 than it does today.
- Landlords should be able to become Lifeline recipients on behalf of their tenants. It would be particularly beneficial if landlords could require tenants to assign them the Lifeline as a component of a rental agreement. For the assignment of Lifeline, a landlord would provide free broadband.
My other comments to the Working Committee were related to the giant subsidy programs in the High-Cost Program. Anybody who has been reading my blog knows that I think the FCC has done a poor job with some of these large subsidy programs.
The CAF II program that gave over $10 billion to the largest telcos was nearly a total failure. Telcos were supposed to use the money to upgrade rural DSL to 10/1 Mbps – but the program started making subsidy payments in the same year that the FCC increased the definition of broadband to 25/3 Mbps. There have been wide criticisms that the telcos never made many of the upgrades and just pocketed the summaries, such as this complaint filed by the Public Service Commission of Mississippi.
RDOF was not a massive failure and, in many cases, was successful, like with the many cooperatives that used the funding to build fiber to their members. But like CAF II, RDOF also failed in many ways. The program started by using terrible FCC broadband maps to define the RDOF areas, and this effort missed many millions of locations that should have been eligible, as witnessed by the many locations not eligible for BEAD. The program ended up with massive defaults on 1.9 million of the 5.2 million locations in the reverse auction. Probably the biggest problem was the mess the RDOF awards made of the broadband landscape by awarding a subsidy to a hodge-podge group of Census blocks that were interspersed with Census blocks that should have been included. This has made it highly challenging to find a broadband solution for the remaining areas and is a big reason that BEAD grant costs are higher than what people think they should be.
My recommendation to the Working Committee is that Congress should not allow the FCC to unilaterally create new giant subsidy programs on its own. It’s poised to launch the 5G for Rural America Fund that looks to have as many problems as the other past programs. Congress should find some way to get buy-in for new programs from outside the FCC. This sounds like a major criticism of the FCC, but this is a regulatory agency that is not staffed by folks who are attuned to what it takes to lure ISPs and carriers to solve the broadband and cellular gaps in rural America.








